Augus Place West - EPBC submission

Current Angus Place West Referral
Name and Address
Complete

Angus Place West coal mine extension – proposed Controlled Action (2022/09270)

Centennial Coal is proposing an underground coal mine extension, Angus Place West, under the very headwaters of the Coxs River and under spectacular Kangaroo Creek. The company has made an application under the Federal environmental laws (the EPBC Act) and the public has been given just a few days to comment on how this proposal will impact on national heritage values.

For over a decade Centennial Coal denied that its mining had devastated rare upland swamps on Newnes Plateau. Eventually, with too many dead swamps, impact was accepted. Now Centennial claims that swamps potentially impacted by this proposal are not nationally significant.

In 2011 Centennial Coal paid $1.45 million to the Federal Government for swamp damage “Without conceding that it has breached the EPBC Act or any other Act”. Research paid for with these funds has mapped the swamps in the Angus Place West proposal as being nationally significant. Despite this, the proponent now claims these swamps aren't nationally significant.

We need to tell the regulators that "the public is watching" to ensure that the independent expert indentification of these swamps as nationally endangered is applied to the Angus PLace West proposal. The public submission deadline is 25 July 2022. More background information on the national heritage values at risk from this proposal.

Please make a submission either by clicking on the EPBC referral number 2022/09270 and then lodge your submission on the Government's website using the points below (preferrred option) or you can edit the following guide letter to make a submission using the webform below:

EPBC Referral Submission

Referrals Gateway
Department of Climate Change, Energy, the Environment and Water
GPO Box 787
Canberra ACT 2601

Dear Sir/Madam,

Re: Angus Place West - EPBC Ref# 2022/09270 referral

As outlined in the detailed submission made by the Lithgow Environment Group, I am concerned that the proposed underground coal mining has the potential to impact: 
•	10 EPBC Listed Threatened Species and Ecological Communities, including the Giant Burrowing Frog; 
•	17 NSW BCA listed Threatened Species, including the Giant Dragonfly; 
•	2 EPBC Listed Migratory Species; 
•	The Sydney drinking water catchment area; and 
•	Adversely impact the Greater Blue Mountains World Heritage Area though loss of headwater flows.

Centennial Coal’s referral understates the size of the nationally endangered wetlands in its referral application. These swamps are not “small patches of freshwater wetland habitat (ie permanently or seasonally saturated land) associated with Coxs River, Kangaroo Creek and Lambs Creek.” The potentially impacted nationally endangered wetlands are large and permanent, with Long Swamp extending over kilometres.

I am concerned that the proposed mining under Kangaroo Creek and within 60 metres of the Coxs River will significantly impact near surface groundwater and surface waters essential for the survival of the above swamps. Former mining by Baal Bone colliery of an area adjoining the Long Swamp to the north was observed in 2011 to lower groundwater levels in the northern tip of Long Swamp when 400 metres distant. This drawdown was due to the Coxs River being associated with a large north-south running fault complex.

When Centennial Coal’s mine workings approach the fractured strata associated with the Coxs River, far field drawdown of near surface groundwater can be expected to drain nationally endangered Long Swamp. Mining under Kangaroo Creek can be expected to have similar consequences to its nationally endangered swamp.

The referral claims these large swamps are not nationally significant Temperate Highland Peat Swamps on Sandstone (THPSS). The Temperate Highland Peat Swamps on Sandstone are officially mapped in the upper reaches of the Coxs River at Long Swamp, and at Kangaroo and Lambs Creeks. This mapping research was paid for with the $1.45 million enforceable undertaking by Centennial Coal due to swamp damage including by the Angus Place mine. This national heritage swamp mapping must now surely make this proposed mining a controlled action.

The impact of water resources should also be a controlled action. Flows from swamps, streams or near surface groundwater into the Angus Place mine through intersecting rock fracture lineaments are resources taken from the Sydney water supply catchment. These flows are then transferred to the Mt Piper Power Plant.

Thank you for the opportunity to comment.

Yours faithfully,